DOL Relaunches Reporting Program

On April 6th, 2021, the Department of Labor (DOL) announced the relaunch of a previously utilized reporting program. The Persuader Reporting Orientation Program (PROP) is a compliance initiative that informs employers about reporting obligations. Specifically, the initiative addresses reporting obligations under the Labor-Management Reporting and Disclosure Act (LMRDA). The PROP initiative was in effect previously from 2011 to 2016. This announcement follows recent activity taken by the DOL. For example, in March 2021, the DOL proposed an 18-month delay to a prevailing wage rule's effective date.

Overview of the LMRDA

In short, the LMRDA requires employers and labor relations consultants to file reports with the Office of Labor-Management Standards (OLMS). For example, these reports could include agreements or arrangements to persuade employees concerning their rights to organize and bargain collectively. Employers and consultants must also report agreements or understandings that contain specific information on employees and labor organizations. This information is usually in connection with a labor dispute involving the employer. Accordingly, these reports inform workers better in determining their rights to organize and bargain collectively. To clarify, the OLMS administers and enforces provisions of the LMRDA. The LMRDA promotes:

• union democracy and financial integrity in private sector labor unions;
• transparency for labor unions and their officials; and
• needed clarity for employers and their labor relations consultants and others.

A Look at PROP

According to the DOL, PROP enables the OLMS to contact employers involved in elections to inform them of reporting requirements. Likewise, the reporting program also advises other parties who act as representatives for such employers during elections. Additionally, the OLMS provides information on locating reporting forms and instructions used in the reporting program. Information on how to contact the OLMS to ask questions is also available. OLMS has also provided a fact sheet on employer-consultant agreements. The DOL or the OLMS could release other fact sheets on the latest PROP iteration later.